1. EPA Hazardous Waste Exports – Transitioning to Electronic Filing at the Border May 8, 2017

2. RCRA Export Border Process Transition
Mandatory Transition – As of 12/31/16, hazardous waste export requirements includes a mandatory transition from paper to electronic at the border for individual shipments in 40 CFR (a)(6).
Old paper process
Attach paper documentation of consent (e.g., Acknowledgement of Consent letter or movement document) to the RCRA manifest, or to shipping papers if waste is exempted (e.g. SLABs and universal waste);
Provide transporter with additional copy of RCRA manifest and instruct transporter via mail, or fax to deliver that copy to the U.S. Customs official at the point the hazardous waste leaves the United States.
New electronic process
Submit Electronic Export Information (EEI) for each shipment to the Automated Export System (AES*) in accordance with 15 CFR 30.4(b), and include EPA-specific information along with the other information required under 15 CFR 30.6.
EPA’s Acknowledgement of Consent letter is the equivalent of an export license defined in 15 CFR 30.1, so exporters are required to submit Electronic Export Information (EEI) for each export shipment per 15 CFR 30.2(a)(iv)(F) regardless of shipment value or destination country.
*AES is run by U.S. Customs and Border Protection

3. Make sure you can pass the automatic checks in AES
Transition Status
Pilot ended, transition period began. – 12/31/2016
During the transition period, exporters can
(1) solely follow the paper process
(2) solely follow the electronic process
(3) test file in AES per the electronic process while instructing the transporter to follow the paper process.
So far, no significant jump in filings. Do not wait, File Now!
When the transition period ends, no later than 12/31/17, U.S. exporters MUST follow the electronic process.
BEFORE you file –Test!
Make sure you can pass the automatic checks in AES

4. What to file….
EPA License Required Indicator - If ‘Y’, information below is required.
EPA Consent Number - Consent number, including waste stream number, from the Acknowledgement of Consent Letter is mandatory.
For example: if your consent number for waste stream one is /12E/13.001, you would remove special characters and provide E13001.
RCRA Hazardous Waste Manifest Tracking Number - EPA RCRA Hazardous Waste Manifest Number (OMB Form # ) associated with the export is conditionally required if waste is required to be RCRA manifested (not CBP manifested) within the United States.
For example: FLE.
EPA Net Quantity Unit of Measure - Conditionally required if neither CL1 nor CL2 quantity are the unit of measure indicated for the AOC. KG are required if waste is solid, L is required if waste is liquid or sludge.
EPA Net Quantity - Quantity of the export for Unit of Measure provided. Conditionally required if neither CL1 nor CL2 quantity are the unit of measure indicated for the AOC.
For example:

5. Field Layout for PGA and EPA License Info AESTIR PGA Line
EDI Format
Field Layout for PGA and EPA License Info AESTIR PGA Line
PGAEP1Y007071E FLEKG
License Required Indicator
EPA Consent Number
RCRA Haz Waste Manifest Tracking Number
EPA Net Quantity UOM
EPA Net Quantity

6. Field Layout for PGA and EPA License Info AESTIR PGA Line
X.12 Format
Field Layout for PGA and EPA License Info AESTIR PGA Line
MAN*ZZ*EP1*Y007071E FLEKG
License Required Indicator
EPA Consent Number
RCRA Haz Waste Manifest Tracking Number
EPA Net Quantity UOM
EPA Net Quantity

7. Note: You may add multiple commodity lines by selecting Add Line.
AES Direct
New Commodity Line Details Screen
Note: You may add multiple commodity lines by selecting Add Line.

8. EPA License Data Screen Input
AES Direct
EPA License Data Screen Input
007071E13001
FLE KG
AES Direct User Guide:

9. Roles of Key Parties Exporter Software Vendor Broker/Filer
Know what you need to file
Be able to provide all required information (electronically) to Broker/Filer
Software Vendor
Understand CBP and EPA AESTIR Information
Program to meet AESTIR Standards
Complete testing in CERT environment
Broker/Filer
Test internal systems for correct PGA Line data
Test in CERT environment